At [Steelhead Group] – (“Steelhead”, “we”, “us” or “our” in this Policy), we are committed to respecting your privacy and protecting the personal data (as set out below) that we obtain and hold about you and others.
Steelhead operates The Last Glaciers website available at [https://www.thelastglaciers.com/] (the “Website”), the services available through the Website such as our newsletter sign up, Lifestyle Calculator and contact forms (together, the “Services”).
- learn about the Last Glaciers Film, the cause behind the film and the actions you can take to help combat climate change;
- take our Lifestyle Calculator to calculate your carbon footprint and provide you with a snapshot of your impact on the planet;
- sign up to our newsletter; and
- contact us for more information.
Where we decide the purpose or means for the processing of the personal data we obtain when you use our Services, we are the data controller for the purposes of the General Data Protection Regulation 2016/679 and the General Data Protection Regulation as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018.
Our Website may contain hyperlinks to third-party websites. These websites operate fully independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our website is not an endorsement. Should you use any of these websites, such use is at your own risk and we would recommend that you review their respective privacy policies and terms and conditions.
2.0 What information may we collect about you?
INFORMATION PROVIDED BY YOU WHEN USING OUR SERVICES
You may give us information about you by filling in forms or surveys when using our Services such as signing up to our newsletter, contacting us with enquiries via our ‘send a message’ form or email, or when taking our Lifestyle Calculator. Such information may include:
- Identity and contact data
including your name and email address.
- Newsletter preferences
whether you wish to opt-in to receive our newsletter or not.
- Enquiry data
including any information you submit to us in messages and correspondence.
- Lifestyle Calculator data
including the country you live in, the number of people in your household, the size of your home, whether you recycle various materials (glass, plastic, metal, organic, paper and cardboard), the type of electricity contract you have, your household’s yearly electricity usage, your primary source of heating, whether you use natural gas for regular cooking, your household’s yearly water usage, whether you own a car or motorcycle and what type you own, how many kilometers you drive per year, whether you have a second car or motorcycle, the number of flights you take per year, their distance and whether they are business class, the number of nights you spend in hotels per year, how regularly you travel by taxi, the minutes you spend per day traveling by bus, subway and/or tram, how many clothes and shoes you purchase per year and whether they are second hand, whether you have your goods delivered to your home and how frequently they are delivered, how many domestic appliances, smartphones, laptops and / or desktops you bought in the last year, the amount you spend on furniture per year, the amount you spend on cultural and sports events per year, the amount you spend on beauty salons and hairdressing per year, and whether your diet is vegan, vegetarian, pescatarian or meat based.
- Cookie preferences
INFORMATION RELATING TO HOW YOU USE THE SERVICES (ANALYTICS)
When you use our Services, we may collect the following data points, which we will anonymise and aggregate:
- number of visitors to our Website;
- pages visited while at the Website and time spent per page;
- page interaction information, such as scrolling, clicks and browsing methods;
- the websites where visitors have come from and where visitors go after accessing our Website;
- page response times; and
- other technical information relating to end user device, such as IP address or browser plugin.
INFORMATION COLLECTED IN RELATION TO SOCIAL MEDIA CHANNELS
Should you visit our social media pages and choose to interact with our content, follow or connect with us on social media, we may process personal data from your social media profile or the social media providers (depending on your social media privacy settings), including:
- your name (and/or your social media unique user name);
- your email and/or postal address;
- your telephone number(s);
- IP or MAC address;
- your gender and/or age; and
- your general interests and preferences (e.g. Likes, Shares, Posts).
3.0 Why do we use your personal data and on what legal basis?
TO PROVIDE THE SERVICES TO YOU
We may use and retain your identity and contact data, enquiry data and Lifestyle Calculator data where we need to in line with our legitimate interests to administer the Website, provide our Services and run our business, or on the basis of providing our Services pursuant to the contract we are about to enter into, or have entered into with you (i.e. our website terms and conditions).
TO RESPOND TO YOUR ENQUIRIES AND REQUESTS FOR SUPPORT
You are under no obligation to provide us with any details, but if you choose not to provide us with relevant information, we may not be able to respond and/or provide the assistance that you request.
We may process your identity and contact data and enquiry data to pursue our legitimate interests of administering the Website, providing our Services and promoting our cause by:
- responding to your enquiry or request for support;
- ensuring our Services function properly so that you and other users have the best support and experience;
- improving the quality of our Services; and
- identifying and correcting any bugs
TO SEND YOU OUR EMAIL MARKETING
If you ask to be added to our mailing list by subscribing to our newsletter, we will keep you updated with information on news, offers, and updates about us and our Services and will process your identity name, email address, and newsletter preference data in order to do so.
We rely upon your consent in order for us to undertake this data processing. You can revoke this consent at any time and let us know you would like to be removed from our mailing list by clicking unsubscribe at the bottom of any marketing email that you receive from us or by emailing firstname.lastname@example.org
TO COMPLY WITH OUR LEGAL OBLIGATION TO SEEK CONSENT FOR THE PLACEMENT OF CERTAIN COOKIES
We process your cookie preferences data in order to comply with, and on the basis of, our legal obligation to request this consent before placing certain cookies on your device.
TO HELP US IMPROVE THE SERVICES AND FIX ANY PROBLEMS
We may process information about you so that we can analyse and improve our Services through knowledge of how the Services are used. This processing is based on your consent or undertaken where it is necessary for us to pursue our legitimate interests of (i) ensuring that our Services function properly so that you and other users have the best experience; (ii) improving the quality of our Services; and (iii) identifying and correcting any bugs.
TO PROTECT OUR SERVICES AND COMPLY WITH THE LAW
If you send us objectionable content or otherwise behave in a disruptive manner, we may process personal data included in your messages to respond to and stop such behavior.
We only process personal data in this way for the legitimate interests of ensuring that use of our Services is lawful, does not disrupt our systems, does not harass our staff or other individuals, and to enforce our legal rights and to comply with our legal obligations.
Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your personal data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
Where we process personal data in this way, we will hold that personal data on our systems for as long as is reasonably necessary to achieve these objectives.
4.0 Do we share your information?
We keep your information confidential, but may disclose it to our group members, suppliers and subcontractors and partners insofar as it is reasonably necessary for the purposes set out in this Policy – please see further detail on our potential sharing of your personal data below:
- Group members
- Suppliers and subcontractors
We also share your personal data with our carefully selected third-party suppliers that carry out certain functions for us and we only provide them with as little personal data as possible to carry out these functions. Activities which are carried out by or in collaboration with third-party suppliers include hosting & IT infrastructure.
We will also share your personal data with our partners that carry out certain functions for us and we only provide them with as little personal data as necessary for these functions. The organisations that will receive your personal data are Leeson Media International, Far North Productions Limited, Blazing Griffin, BNP Paribas S.A., Lowa (TKC Sales Limited), Arc’teryx (Amer Sports Canada Inc), Meru Projects and Big Agnes Inc.
- Merger or acquisition
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may be required to share your personal data with the buyer. You will be notified via account message and/or a prominent notice on our Platform of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
- Required by law
In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
We may also disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our users, or others.
5.0 Your rights in relation to your personal data which we process.
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:
- for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
- to restrict, stop processing, or to delete your personal data;
- for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
- to make a complaint to a data protection regulator. For example, in the UK this is the Information Commissioner and you may contact them at: https://ico.org.uk/concerns/
To make a request in relation to any of the aforementioned rights, please send your requests to email@example.com
We do not knowingly solicit information from or market to children under the age of 13. In the event that we learn that we have collected personal data from a child under 13 years of age we will delete that information as quickly as possible. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at firstname.lastname@example.org
We will take appropriate technical and organizational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our users.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorized disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Website and your personal data a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal data with us, you accept the aforesaid and provide your information at your own risk.
8.0 International Data Transfers
We are a [company based in Hong Kong] and our servers are located in the UK and the information that we collect directly from you will be stored in these servers.
We have are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses.
If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at email@example.com. To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
9.0 Retention Periods or Criteria
We will hold your personal data for as long as is necessary for the relevant purpose for which that personal data was obtained, or as otherwise described in this Policy.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you would like us to stop using or holding your personal data and/or would like to request its deletion, please email us at firstname.lastname@example.org
This Policy may be updated from time to time. We will notify you of any changes by posting the new Policy to this page.
11.0 Contact Us
Questions, comments and requests in relation to this Policy are welcome and should be addressed to email@example.com